Privacy policy
Read our privacy policies
Privacy policy
On this page you will find privacy policies for
- Diers Klinik ApS, which performs insemination treatments (IUI), and
- Diers IVF ApS, which performs IVF and egg donation treatments.
Privacy Policy for Customers, Clients, Patients and Known Donors
1. Introduction
At Diers Klinik ApS (“Diers Klinik”, “we”, “us” or “our”), we process personal data in connection with fertility treatment, related healthcare services, and the reservation, storage, sale and distribution of donor sperm.
This privacy policy explains how we process personal data when:
- you contact us about fertility treatment, donor sperm or related services,
- you receive treatment at our clinic,
- you purchase, reserve or store donor sperm through us,
- you purchase donor sperm from us for delivery to another fertility clinic where treatment will take place,
- you participate as a known donor in a client’s/patient’s treatment pathway by prior agreement, or
- you otherwise use our services as a customer/client/patient.
2. Data Controller
Diers Klinik ApS
CVR no. 33047991
Store Torv 8, 3rd floor
8000 Aarhus C
Denmark
Email: [email protected]
Telephone: +45 20 22 85 87
If you have any questions about this privacy policy or our processing of your personal data, you are welcome to contact us.
3. Scope
This privacy policy applies to:
- clients/patients receiving treatment at Diers Klinik,
- customers purchasing, reserving or storing donor sperm through Diers Klinik,
- customers purchasing donor sperm from Diers Klinik for delivery to another fertility clinic,
- clients/customers with donor sperm in storage,
- known donors participating in a specific treatment pathway by prior agreement,
- partners of clients/patients where relevant to treatment, legal requirements or documentation,
- potential clients/customers contacting us about treatment or the purchase of donor sperm, and
- users of our website or digital services who submit information to us.
4. Types of Personal Data
Depending on the circumstances, we may process the following categories of personal data.
4.1 General personal data
We may process:
- name,
- CPR number or other identification number,
- date of birth,
- address,
- email address,
- telephone number,
- photo ID or other identity documentation,
- civil status,
- occupation,
- payment and invoicing information,
- communication history,
- appointment, enquiry, order and purchase information,
- information about reservation, storage, release, shipment and delivery of donor sperm,
- information about the receiving fertility clinic where donor sperm is to be delivered,
- information about donor choice, donor number, donor type and relevant product details,
- information about treatment outcome where relevant to medical, legal, quality, safety and traceability obligations,
- information about partners of clients/patients and known donors,
- website account and login information.
4.2 Special categories of personal data
As a fertility clinic, we may also process sensitive personal data, including:
- health data, including medical history, medical records, diagnoses, treatment information, test results and treatment outcomes,
- information relating to fertility status and reproductive health,
- genetic data,
- information that may indirectly reveal sexual orientation or family situation, for example through information about a partner, treatment type or known donor arrangements,
- information about racial or ethnic origin,
- where a known donor is involved in a treatment pathway, we may also process relevant health data, including information about reproductive health and genetic data, relating to that known donor to the extent necessary for the treatment and to comply with applicable law.
5. Collection of Personal Data
We usually collect personal data directly from you.
Where relevant, we may also receive personal data from:
- a partner or known donor involved in the treatment pathway,
- another fertility clinic or healthcare professional,
- laboratories in connection with testing or analysis,
- public authorities where required or permitted by law,
- transport or logistics providers involved in the delivery of donor sperm,
- our website and communication systems when you contact us or use our digital services.
6. Purposes of Processing
We process personal data for one or more of the following purposes, depending on the nature of your engagement with us:
- to assess, plan, provide and follow up on fertility treatment and related healthcare services,
- to communicate with you before, during and after treatment,
- to create and maintain medical records and other required documentation,
- to administer reservations, purchases, storage, release, shipment, delivery and distribution of donor sperm,
- to coordinate with receiving fertility clinics where donor sperm purchased from us is to be used outside our own clinic,
- to process direct sales of donor sperm to private individuals for treatment at another fertility clinic,
- to process sales or distribution of donor sperm to external fertility clinics,
- to manage treatments involving known donors,
- to comply with legal requirements relating to quality, safety, documentation, vigilance and traceability in connection with the handling and use of donor sperm and other human tissues and cells,
- to investigate and manage adverse events, adverse reactions, complaints and safety incidents,
- to comply with legal requirements relating to reporting, pregnancy limits and traceability from donor to recipient and vice versa,
- to manage payment, invoicing and accounting,
- to manage website logins and customer accounts where relevant,
- to protect our systems, data and business operations,
- to handle enquiries, complaints, inspections, supervisory requests and other legal claims,
- to prepare statistics, internal reporting and documentation, and
- where permitted by law, to support scientific or quality-related follow-up work.
7. Legal Basis for Processing
The legal basis depends on the specific processing activity.
7.1 General personal data
We process general personal data on one or more of the following bases under Article 6 of the GDPR:
- Article 6(1)(b), where processing is necessary in order to take steps at your request before entering into an agreement or to perform an agreement with you,
- Article 6(1)(c), where processing is necessary for compliance with a legal obligation to which we are subject,
- Article 6(1)(f), where processing is necessary for our legitimate interests, provided those interests are not overridden by your interests or fundamental rights and freedoms,
- Article 6(1)(a), where we specifically rely on your consent.
7.2 Special categories of personal data
We process health data and other special categories of personal data on one or more of the following bases under Article 9 of the GDPR, where relevant:
- Article 9(2)(a), explicit consent,
- Article 9(2)(f), where necessary for the establishment, exercise or defence of legal claims,
- Article 9(2)(h), where necessary for the provision of healthcare or treatment and the management of healthcare systems and services,
- Article 9(2)(i), where necessary for reasons of public interest in the area of public health, including high standards of quality and safety for healthcare and human tissues and cells.
7.3 Applicable legislation
In addition to the GDPR and the Danish Data Protection Act, our processing may also be governed by applicable Danish healthcare and tissue legislation, including rules on assisted reproduction, medical record keeping, traceability, and quality and safety in relation to human tissues and cells.
8. Consent
In some situations, we may ask for your consent to process specific personal data or to collect information from third parties.
If processing is based on your consent, you may withdraw that consent at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.
Please note that even if you withdraw consent, we may still be required to retain and process certain personal data where this is necessary to comply with legal obligations, including healthcare documentation, traceability, safety and medical record-keeping requirements.
9. Is It Mandatory to Provide Personal Data?
When we collect personal data directly from you, you generally provide the information voluntarily.
In many cases, however, we need certain personal data in order to:
- assess whether we can offer treatment or services,
- provide fertility treatment or donor sperm-related services,
- complete delivery arrangements to the relevant receiving clinic,
- comply with legal and regulatory requirements, and
- ensure correct identification, documentation, safety and traceability.
If you do not provide the information we need, the consequence may be that we cannot offer treatment, supply donor sperm or otherwise provide the requested service.
10. Disclosure of Personal Data
We only share personal data where relevant and necessary.
Depending on the circumstances, we may disclose or make personal data available to:
- public authorities and supervisory bodies, where required by law or legal obligations,
- other fertility clinics or healthcare professionals involved in your treatment or in the receipt and use of donor sperm purchased from us,
- laboratories involved in required testing or analysis,
- transport and logistics providers involved in shipment or delivery of donor sperm,
- IT, hosting, backup, website, communication and software providers acting as our data processors,
- payment, bookkeeping and auditing providers where relevant,
- legal advisers, insurers or other professional advisers where relevant in connection with complaints, disputes or claims,
- Diers IVF, if an email has mistakenly been sent to Diers Klinik.
Where a known donor is involved in a patient’s treatment pathway, relevant information may also be shared to the extent necessary for treatment, documentation, safety, traceability and compliance with applicable law.
11. Data Processors
We use data processors who process personal data on our behalf and under our instructions.
These may include providers of:
- patient record systems and other healthcare software,
- secure email solutions,
- cloud hosting and backup services,
- website hosting and related digital infrastructure,
- IT support,
- laboratory or testing systems,
- accounting or administrative systems.
We require our data processors to implement appropriate technical and organisational security measures and to process personal data only in accordance with our instructions and applicable law.
12. International Transfers
If, in specific cases, personal data is transferred to a country outside the EU/EEA, we will ensure that such transfer takes place in accordance with applicable data protection law and on the basis of a valid transfer mechanism.
You may contact us if you would like more information about any such transfers.
13. Retention Periods
We keep personal data for no longer than necessary, but certain information must be retained for fixed statutory periods.
13.1 Traceability and tissue-related documentation
Where personal data forms part of the documentation required to ensure full traceability in connection with donor sperm and other human tissues and cells, we retain the relevant information for the period required by applicable law.
13.2 Medical records
Where you are treated by us as a patient, we retain your medical records for the period required under applicable rules on medical record keeping.
13.3 Customers who do not proceed
If you contact us or provide information to us but do not proceed to treatment, purchase or another service, we retain your information only for as long as necessary for the relevant purpose and in accordance with applicable law and our internal retention procedures.
13.4 Complaints and legal claims
We may retain personal data for longer where necessary in connection with complaints, compensation matters, supervisory matters, disputes or legal claims.
14. Your Rights
Under data protection law, you have a number of rights in relation to our processing of your personal data.
Depending on the circumstances, these may include:
- the right of access,
- the right to rectification,
- the right to erasure,
- the right to restriction of processing,
- the right to object, and
- where relevant, the right to withdraw consent.
These rights are not absolute. In some situations, our legal obligations relating to healthcare documentation, traceability, safety, public health, or the establishment, exercise or defence of legal claims may mean that we cannot fully comply with a request, or that we can only comply with it to a limited extent.
If you would like to exercise your rights, please contact us using the contact details above.
15. Data Security
We take appropriate technical and organisational security measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure and unauthorised access.
Our security measures are designed with regard to the nature of the personal data we process, including health data and other sensitive data, and the risks associated with our activities as a fertility clinic and with the handling of donor sperm.
16. Changes to This Privacy Policy
We may update this privacy policy from time to time.
The most recent version will always be available on our website.
Where relevant, we will also inform you of significant changes in an appropriate manner.
17. Complaints
If you have questions about how we process your personal data, please contact us first. We will do our best to answer your questions.
You also have the right to lodge a complaint with the Danish Data Protection Agency.
Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
Denmark
Website: www.datatilsynet.dk
Date: Version 21.04.2026.
Privacy policy for Diers IVF ApS – Patients and egg donors
Processing of information
As a patient/donor at Diers IVF, we collect and process a number of personal data about you. This privacy policy describes how Diers IVF processes, uses and discloses your personal data.
Types of information
Diers IVF collects and processes the following types of personal data about you:
General categories of personal data
The patient’s (including donor/depositor) name, personal identification number (CPR number), email address, home address and telephone number, as well as information regarding weight, height, smoking and alcohol habits, photo ID, bank details, social circumstances, family relations, employment/education, and information about the patient’s choice of donor sperm/eggs (type and donor name).
Where applicable, the partner’s name, personal identification number, weight, height, and smoking/alcohol habits.
For egg donors additionally: hair colour, eye colour, blood type, zodiac sign, dominant hand, use of glasses/contact lenses, childhood photos, education/occupation, a description of the donor based on the staff’s impression, and the information provided in the donor profile questionnaire.
Special categories of personal data (“sensitive personal data”)
Race or ethnic origin
Health information (patient/egg donor), including medical records regarding various health conditions, diagnoses, medical history, treatment, test results, tests, X-rays, etc.
Sexual relationships or orientation in the form of information about any partner and marital status – thereby indirectly providing information about the sexual observance of the patient and any partner.
Genetic data (blood sample from patient/donor).
Purpose
We process your personal data for the following purposes:
- The main purpose of the processing of personal data is to carry out the healthcare treatment of our patients and egg donors according to applicable regulations and healthcare standards.
- To comply with the standards set for quality and safety in the collection, testing, processing, preservation, storage and distribution of gametes and assisted reproduction with gametes. The rules are laid down in the EU directive on tissues and cells and implemented in Danish legislation in the Tissue Act, the Executive Order on Tissues, the Act on assisted reproduction in connection with treatment, diagnostics and research etc.
- Screening of egg donors
- Investigation of serious adverse events and side effects
- Compliance with rules on geographical spread and number of donor children with donated gametes
- Ensuring traceability from donor to recipient and vice versa
- Comply with our obligations under applicable legislation, including the Danish Tissue Act, the EU Data Protection Regulation, the Danish Data Protection Act, the Danish Executive Order on Record Keeping and other relevant health legislation, e.g.
- Documentation/record keeping obligations.
- Compliance with basic principles of personal data processing and legal basis for processing.
- Implementing and maintaining technical and organisational security measures.
- Investigating suspected or known security breaches and reporting to individuals and authorities.
- Handling enquiries and complaints from data subjects and others.
- Handling inspections and enquiries from supervisory authorities.
- Handling disputes with data subjects and third parties.
- Statistical studies and scientific research.
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Preparation of a donor profile and presentation of the egg donor on the clinic’s donor page (the page is password-protected, and all personal data are presented in pseudonymised form).
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Presentation of the egg donor on the website and in marketing materials using the donor name, childhood photos, height, weight, hair colour, eye colour, and a short description of the donor.
Volunteering
When we collect personal data directly from you, you provide the personal data voluntarily. You are not obliged to provide this personal data to us. The consequence of not providing us with the personal data will be that we will not be able to fulfil the purposes above and that, as a result, in many cases we will not be able to process you.
Sources
In some cases, we collect personal data about you from other healthcare professionals (after prior agreement with you) or from laboratories in connection with testing. We also obtain information about test results from the Laboratory Results portal for patients, including egg donors. We process the information received in accordance with this privacy policy.
Disclosure of personal data
To the extent necessary in the specific process, your personal data will be disclosed and shared with the following recipients,
- Authorities when required under the rules of the Danish Tissue Act, the Danish Assisted Reproduction Act and special legislation – e.g. the Danish Patient Safety Authority, the Danish Health Authority, the Danish Health Data Authority (SEI), the Common Medical Card, the police and social authorities to the extent required by applicable Danish legislation
- Other fertility clinics, hospitals or healthcare professionals by prior specific agreement with the patient/depositor or by referral
- Testing laboratories
- Pharmacies and the Danish Medicines Agency via the prescription server when issuing prescriptions
- Shipping company
- Regarding egg donors: The information contained in the donor profile is disclosed to potential recipients of donor eggs. The identity of the egg donor will be disclosed, upon request, to donor-conceived children once they have reached the age of 18.
- Forwarding emails to Diers Klinik that have been sent to Diers IVF in error
Legal basis for processing and disclosure of personal data
The legal basis for collecting, processing and disclosing your personal data is,
- In the process, general personal data is collected, processed and disclosed pursuant to Article 6(1)(a), (b), (c) and (d) of the GDPR, while sensitive personal data is collected, processed and disclosed pursuant to Article 9(2)(a), (b), (c), (f), (h) and (i) of the GDPR.
- The obligations to collect, process and disclose personal data in connection with fertility treatment with gametes are set out in the Act on Assisted Reproduction in Connection with Treatment, Diagnostics and Research etc., the Executive Order on Assisted Reproduction and the EU Directive on Tissues and Cells and implemented in Danish legislation in the Tissue Act and the Executive Order on Tissues and the Children Act.
- Health information for further treatment when referring patients is disclosed in accordance with the rules in the Agreement on specialised medical care §§ 20-23 and the Danish Health Act.
- Laboratory samples are reported to laboratories in accordance with the rules in the Danish Health Authority’s guidelines on the handling of paraclinical examinations pursuant to the Danish Authorisation Act.
- In addition, we are obliged to process a number of personal data about you pursuant to chapter 6 of the Danish Authorisation Act, the Executive Order on Health Professionals’ Medical Records (the Executive Order on Medical Records), especially sections 5-10, and chapter 9 of the Danish Health Act.
- Prescriptions are sent via the IT service Receptserveren in accordance with the rules in Chapter 42 of the Danish Health Act and the Executive Order on Prescriptions and Dispensing of Medicines, especially Chapter 3.
- Clinical patient data is disclosed to clinical databases in accordance with the rules in sections 195-196 of the Danish Health Act and the executive order on reporting information to clinical quality databases etc. Data can also be disclosed on the basis of a specific consent from you as a patient, for example if you wish to participate in research projects.
- Epicrises, which are a brief summary of the patient’s medical history and course of treatment, are sent to the referring physician and in some cases to the referring hospital in accordance with the rules in Chapter 9 of the Health Act.
- Your personal data will only be disclosed to your next of kin with your prior consent in accordance with the rules in section 43 of the Danish Health Act.
- In the case of deceased patients, certain personal data may be disclosed to the deceased’s next of kin, the deceased’s general practitioner and the doctor who treated the deceased in accordance with the rules in section 45 of the Danish Health Act.
Withdrawal of consent
If the processing of your personal data is based on consent, you have the right to withdraw consent. If you withdraw consent, it will not affect the processing prior to the withdrawal of consent, including a disclosure based on consent.
Use of data processors
Your personal data may be processed and stored by our data processors who store it on our behalf and on our instructions. Our data processors include:
- IT software provider
- Secure email provider
- IT company providing back-up and support services etc.
- Website company, including domain hosting company
- Testing laboratories
Retention period
We store your personal data for as long as we need to fulfil the purposes stated above. However, according to the Executive Order on Record Keeping, we are obliged to store it for a minimum of 10 years, and according to the Danish Tissue Act and the Executive Order on Human Tissues and Cells, we are obliged to store certain information for a minimum of 30 years after the last entry in the journal. There may be cases where we need to store your personal data for a longer period of time, e.g. in connection with a complaint case, cases of serious side effects/adverse events in connection with donated gametes or compensation cases, in which case the data will be stored until the case is finalised.
Your rights
Under the General Data Protection Regulation, you have a number of rights in relation to Diers IVF’s processing of your data. You can exercise these rights at any time. If you want to exercise your rights, please contact Diers IVF.
Your rights are:
- Right to see your data (right of access)
You have the right to access the data we process about you, as well as a range of additional information. - Right to rectification (rectification)
You have the right to have incorrect information about yourself corrected. Diers IVF has a duty to consider the request. - Right to erasure
In special cases, you have the right to have the information deleted before the time at which it would otherwise be deleted. Diers IVF has a duty to consider the request. - Right to restriction of processing
In certain cases, you have the right to have the processing of your personal data restricted. If you have the right to have the processing restricted, we may in future only process data – except for storage – with your consent, or for the purpose of establishing, exercising or defending a legal claim, or to protect a person or important public interests. - Right to object
In certain cases, you have the right to object to our otherwise lawful processing of your personal data.
You can read more about these rights in the Danish Data Protection Agency’s guide on the rights of data subjects, which is available at www.datatilsynet.dk.
Contact or complain
If you have any questions regarding the processing of your personal data, the utilisation of your rights or if you wish to make a complaint, you are welcome to contact us.
Enquiries can be made to:
Diers IVF ApS (CVR 42054240)
Store Torv 8, 4th floor
8000 Aarhus C, Denmark
CEO Helle Sejersen Myrthue (e-mail: [email protected])
If this does not result in clarification, any complaints can then be directed to the Danish Data Protection Agency. The current contact address can be found at www.datatilsynet.dk.
Date: Version 27 February 2026.
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